Tag: RCRA

Avoiding the Costly Cleanups of Used Oil

Service stations must: Comply with EPA’s used oil management standards, Not mix used oil with any hazardous substance, and Accept used oil from Do-it-yourselfers (DIYs) and send it for recycling. Call the RCRA Hotline for complete details regarding this liability exemption. Some Help with Cleanup EPA recommends used oil handlers follow these cleanup practices: Maximize […]

RCRA Training: Who Needs It?

All Facilities Applicants for a permit to operate a hazardous waste facility must include in the permit application a written outline of both the introductory and continuing training programs by owners or operators to prepare persons to operate or maintain the facility safely. Large Quantity Generators (LQGs) LQGs that accumulate hazardous waste on-site for 90 […]

Hazardous Waste Training: Got It On Record?

In order to manage the wastes safely and properly, your workers at sites that handle them must be trained in waste management techniques and how to respond appropriately to releases that occur. But your training efforts are wasted if you can prove that workers completed it. Keeping good training records is not only good practice, […]

Can Your Clothes Make You Sick? GAO Looking at Formaldehyde in Clothing

While there are no federal limits on formaldehyde in clothing, a recent report by the Government Accountability Office (GAO) may cause Congress and advocacy groups to put pressure on the Consumer Product Safety Commission (CPSC) to revisit the feasibility of imposing such limits. Formaldehyde is a heavily regulated substance and one of a handful of […]

Developing a Good Laboratory Management Plan

The problem is so prevalent at colleges and universities that EPA developed a regulatory option (new RCRA Subpart K), intended to encourage officials in charge of thousands of academic labs to periodically collect old, unneeded, or expired chemicals (legacy chemicals), determine whether these chemicals are hazardous, and properly manage their disposal. If you are an […]

Key Elements of EPA’s Academic Lab Rule

Note that the rule is not regarded by EPA as more stringent than existing regulations. This means that states authorized to run the federal RCRA program are not required to adopt the rule. In fact, while some states have adopted it since promulgation, others have expressed their opposition to it, and the rule may not […]

TRI and Waste Management-Understanding Key Definitions

Waste management is included under the TRI definition of toxic chemicals that are otherwise used, which refers to activities that are not manufacturing or processing. TRI requires that subject facilities report releases and other waste management of listed chemicals. Facilities must also report transfers of toxic chemicals for waste management to off-site locations. Waste management […]

Taking the Confusion Out of ‘Closed Containers’

Notwithstanding the complexity inherent in the phrase closed container, managers must be confident that they understand what must be done with the hazwaste containers at their facilities to ensure that a state or federal inspector will have no doubt that the regulations are being met. Keep in mind that containers in which hazwastes are held […]

The Controversial Contained-In Policy

One way, called the contained-in policy, attempted to smooth over the pre-existing position held by the Agency that contaminated soil that either contained a listed hazardous waste or exhibited a hazardous waste characteristic must be managed and disposed of according to all regulations governing hazardous waste (RCRA Subtitle C). Also, soil that contained listed hazardous […]

Hazardous Waste Container Definitions that Stump Everyone

Containers & Tanks There’s a lot of confusion around whether a management unit is a container or a tank. Here’s the difference—you know you’re dealing with a hazardous waste container if it’s portable. A tank will always remain stationary. The RCRA hazardous waste regulations define a container as “any portable device in which a material […]